IMPACT — MEDIUM

The U.K. Home Office published guidance and reporting requirements for employers who sponsor remote workers.

Key Points:

  • Sponsors must report through the Sponsor Management System if the sponsored employee:
    • Is or will be working at a different site, branch or office, or a different client’s site, not previously declared to U.K. Visas and Immigration.
    • Is or will be working remotely from home on a permanent or full-time basis (with little or no requirement to physically attend a workplace).
    • Has moved or will be moving to a hybrid working pattern.
  • Individuals are considered to be in a hybrid working pattern if the sponsored employee is working remotely on a regular and planned basis from their home or other location that is not listed on the sponsor license.
  • Sponsors are not required to report day-to-day changes in work locations.

Additional Information: Reports must be made within 10 business days after the change in location. More information regarding the reporting requirements for remote workers is available here.

BAL Analysis: Employers should review the hybrid working pattern guidance to ensure that they adhere to the new reporting requirements.

This alert has been provided by the BAL Global Practice Group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2023 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The State Department released the June Visa Bulletin, showing no movement for key employment-based categories.

Final Action Dates

EB-1

  • China EB-1 will remain at Feb. 1, 2022.
  • India EB-1 will remain at Feb. 1, 2022.
  • All other countries under EB-1 will remain current.

EB-2

  • China EB-2 will remain at June 8, 2019.
  • India EB-2 will remain at Jan. 1, 2011.
  • All other countries under EB-2 will remain at Feb. 15, 2022.

EB-3

  • China EB-3 will remain at April 1, 2019.
  • India EB-3 will remain at June 15, 2012.
  • All other countries under EB-3 will remain at June 1, 2022.

Final Action Dates for Employment-Based Preference Cases:

Preference All Other Countries China India Mexico Philippines
EB-1 Current Feb. 1, 2022 Feb. 1, 2022 Current Current
EB-2 Feb. 15, 2022 June 8, 2019 Jan. 1, 2011 Feb. 15, 2022 Feb. 15, 2022
EB-3 June 1, 2022 April 1, 2019 June 15, 2012 June 1, 2022 June 1, 2022

Dates for Filing

EB-1

  • China EB-1 will remain at June 1, 2022.
  • India EB-1 will remain at June 1, 2022.
  • All other countries under EB-1 will remain current.

EB-2

  • China EB-2 will remain at July 8, 2019.
  • India EB-2 will remain at May 1, 2012.
  • All other countries under EB-2 will remain at Dec. 1, 2022.

EB-3

  • China EB-3 will remain at June 1, 2019.
  • India EB-3 will remain at Aug. 1, 2012.
  • All other countries under EB-3 will remain at May 1, 2023.

Dates for Filing for Employment-Based Preference Cases:

Preference All Other Countries China India Mexico Philippines
EB-1 Current June 1, 2022 June 1, 2022 Current Current
EB-2 Dec. 1, 2022 July 8, 2019 May 1, 2012 Dec. 1, 2022 Dec. 1, 2022
EB-3 May 1, 2023 June 1, 2019 Aug. 1, 2012 May 1, 2023 May 1, 2023

Additional Information: U.S. Citizenship and Immigration Services has not yet announced whether it will use the Final Action Dates or Dates for Filing chart in June. BAL will update clients once USCIS announces which chart will be used.

This alert has been provided by the BAL U.S. Practice Group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2023 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The Labor Department has posted updated processing times for permanent labor certification (PERM) applications and prevailing wage determination (PWD) requests.

PERM Processing: As of April 30, the department was adjudicating applications filed in July and earlier, conducting audit reviews on applications filed in April and earlier, and reviewing appeals for reconsideration filed in August and earlier.

Determinations: February 2023 March 2023 April 2023
Adjudication 264 days 271 days 279 days
Audit Review 383 days 402 days 383 days

PWD Processing: As of April 30, the National Prevailing Wage Center was processing PWD requests filed in January 2022 and earlier for H-1B OES and PERM OES cases, February 2022 and earlier for H-1B non-OES cases, and January 2022 and earlier for PERM non-OES cases. Redeterminations were being considered on appeals filed November and earlier for H-1B cases, and October and earlier for PERM cases.

BAL Analysis: BAL’s internal case tracking is mostly consistent with the Labor Department’s published processing times. BAL is seeing faster PWD issuances for PERM OES and non-OES cases. BAL is seeing approvals for PERM applications filed in July and earlier, and is starting to see PWDs for requests filed in January and earlier for H-1B OES cases, February and earlier for H-1B non-OES cases, and November and earlier for PERM OES and non-OES cases.

This alert has been provided by the BAL U.S. Practice Group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2023 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The U.S. State Department has announced the winners of the 2024 Diversity Visa lottery.

Key Points:

  • DV2024 entrants can check their entries on the Entrant Status Check website. Results will remain posted through Sept. 30, 2024.
  • To check their results, individuals who entered the lottery will need to provide their entry confirmation number, last name and year of birth.
  • Those who are selected in the lottery will be given instructions in Entrant Status Check about how to apply for immigrant visas for themselves and eligible family members.
  • Selected entrants are encouraged to complete the online DS-260 application immediately to schedule an interview appointment at the appropriate U.S. embassy or consulate.
  • The State Department will not mail notification letters or notify selectees by email, nor will U.S. embassies or consulates provide a list of selectees. The Entrant Status Check webpage is the only way to see selections.

Additional Information: The Diversity Visa program provides for 55,000 immigrant visas to be issued to individuals from countries with low levels of immigration to the United States. Individuals register during an annual registration period and are selected through a random lottery. The registration period for fiscal year 2024 Diversity Visas opened Oct. 5, 2022, and closed Nov. 8, 2022.

Individuals who entered the Diversity Visa 2023  program have until Sept. 30, 2023, to check the status of their entry. The DV2023 registration period was from Oct. 6, 2021, through Nov. 9, 2021.

This alert has been provided by the BAL U.S. Practice Group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2023 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

U.S. Immigration and Customs Enforcement announced Thursday that it would give employers 30 days to reach compliance with Form I-9 document inspection requirements once COVID-related I-9 flexibilities come to an end on July 31, 2023.

Key Points:

  • In March 2020, ICE introduced Form I-9 flexible measures that allow employers operating remotely because of COVID-19 to verify employee employment eligibility documents virtually, e.g., by fax, email or video.
  • These measures were extended several times, most recently in October 2022. ICE’s announcement Thursday confirms that these measures will remain in place for eligible employers through July 31, even after the COVID-19 public health emergency ends on May 11.
  • Under the guidance, employers that follow virtual procedures must comply with certain guidelines when “normal operations” resume. Initially, this included conducting physical inspections of documents that were viewed remotely within three business days; ICE has now extended that period to 30 days from the date the temporary measures expire, i.e., until Aug. 30, 2023.

Additional Information: The Department of Homeland Security continues to work on a rule that would give ICE authority to allow remote inspection of documents in some cases. The agency published a proposed rule in August 2022 and received more than 500 public comments, including one from BAL. DHS is currently reviewing the public comments and plans to issue a final rule later this year.

BAL Analysis: The 30-day grace period will give employers some additional time to review documents in person once the temporary flexibilities end; however, this is still a tight time frame, particularly given that some employers have been relying on the temporary policy for more than three years. BAL continues to encourage companies that have not yet started in-person reviews to start planning as soon as possible. BAL will continue to monitor the development of DHS’ new I-9 rule and will provide updates as information becomes available.

This alert has been provided by the BAL U.S. Practice Group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2023 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

U.S. Citizenship and Immigration Services posted a Federal Register notice extending and expanding work authorization for eligible Hong Kong residents who are covered by Deferred Enforced Departure.

Key Points:

  • Eligible Hong Kong residents covered under DED as of Jan. 26, 2023, may remain in the United States through Feb. 5, 2025, and are eligible for work authorization.
  • USCIS is automatically extending the validity of Hong Kong DED-based Employment Authorization Documents through Feb. 5, 2025, for those who already have an EAD with an A-11 category code on the card and an expiration date of Feb. 5, 2023.
  • EADs will remain valid even though the expiration date on the card has passed. An individual does not need to apply for a new EAD to benefit from this automatic EAD extension.
  • There is no application for DED; Hong Kong residents are covered under DED based on the terms described in the president’s directive. Eligible Hong Kong residents may apply for an EAD by filing Form I-765, Application for Employment Authorization.
  • The Department of Homeland Security may provide travel authorization at its discretion to those covered under DED for Hong Kong. Individuals who wish to travel outside of the United States based on DED must file Form I-131, Application for Travel Document, to request advance parole.

Additional Information: The extension and expansion was made to offer safety and protection to Hong Kong residents amid a continued “assault on Hong Kong’s autonomy, undermining its remaining democratic processes and institutions, imposing limits on academic freedom, and cracking down on freedom of the press.” More information on DED is available on this USCIS webpage.

This alert has been provided by the BAL U.S. Practice Group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2023 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The U.S. State Department has provided updated border crossing information to U.S. citizens who are trying to leave Sudan.

Key Points:

  • The U.S. government will inform U.S. citizens of any plans for additional U.S. government-organized convoys from Khartoum to Port Sudan. For those who are able to depart Port Sudan via commercial vessels, U.S. officials are receiving citizens in Jeddah, Saudi Arabia. U.S. citizens should contact the U.S. Consulate General in Jeddah with questions at (+966) 12 220 5000 or email Jeddahacs@state.gov.
  • U.S. citizens in Sudan should fill out this crisis intake form to receive options to leave Sudan as the security situation allows. Individuals do not need to submit this information again if they have already submitted information to the U.S. Embassy in Khartoum.
  • U.S. citizens leaving Sudan should check this website for country-specific border crossing instructions. The State Department has provided instructions for those traveling to Central African Republic, Chad, Egypt, Eritrea, Ethiopia and South Sudan.
  • U.S. citizens in Sudan who are in need of assistance can call the State Department at 1-888-407-4747 (from the United States) or 1-202-501-4444 (from overseas) and enroll in the Smart Traveler Enrollment Program if they have not done so already.

Additional Information: As of April 22, the U.S. Embassy in Khartoum, Sudan, is no longer offering routine or emergency consular services. The State Department suspended such services until further notice. The situation is “violent, volatile and extremely unpredictable, particularly in the capital city Khartoum,” the Department stated.

BAL Analysis: Companies with employees in the country are encouraged to follow State Department information and warnings closely. Wait times at crossing points could vary widely and change quickly. BAL will continue to monitor developments regarding the security situation in Sudan and will provide more information as it becomes available.

This alert has been provided by the BAL U.S. Practice Group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2023 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

The White House announced Monday that it will soon end the COVID-19 vaccination requirement for nonimmigrant international air travelers. The Department of Homeland Security announced it would end the vaccination requirement for non-U.S. travelers entering the U.S. via land ports of entry and ferry terminals.

Key Points:

  • Beginning May 12, the United States will no longer require nonimmigrant foreign nationals to be vaccinated against COVID-19 to enter the country by land, sea or air.
  • Between now and May 12, most nonimmigrant foreign nationals entering the country must continue to show proof that they are fully vaccinated against COVID-19.
  • Further details related to ending these requirements will be released in the coming days.

Background: The Biden administration first introduced the COVID-19 vaccination requirement for international air travelers and those crossing at land borders and ferry terminals in November 2021.

BAL Analysis: The termination of the COVID-19 vaccination requirements will coincide with the end of the national COVID-19 public health emergency. The Biden administration has been reviewing COVID-related immigration policies and, in addition to the vaccination policy, recently ended COVID-related flexible deadlines for responding to some U.S. Citizenship and Immigration Services requests. BAL will continue to monitor the administration’s COVID policies and will provide updates as information becomes available.

This alert has been provided by the BAL U.S. Practice Group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2023 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

Diversity Visa lottery results for fiscal year 2024 will be available on May 6 on the State Department’s Entrant Status Check webpage.

Key Points:

  • Beginning at 12 p.m. ET on May 6, Diversity Visa entrants may check if their online registration was selected at the Department’s Entrant Status Check webpage.
  • Individuals who entered the lottery will need to provide their entry confirmation number, last name and year of birth to check their results.
  • Those who are selected in the lottery will be given instructions in Entrant Status Check about how to apply for immigrant visas for themselves and for eligible family members.
  • The State Department will not mail notification letters or notify selectees by email, nor will U.S. embassies or consulates provide a list of selectees. The Entrant Status Check webpage is the only way to see selections.
  • Entrants should keep their confirmation number until at least Sept. 30, 2024.

Background: The Diversity Visa program provides 55,000 immigrant visas (green cards) per year to individuals from countries with low levels of immigration to the United States. Individuals register during an annual registration period and are selected through a random lottery. The registration period for fiscal year 2024 Diversity Visas opened Oct. 5, 2022, and closed Nov. 8, 2022.

BAL Analysis: Applicants are reminded that the State Department’s Entrant Status Check webpage is the only official source where results are posted. They must use the official website to find out if they have been selected in the lottery and, if selected, to check for the date of their immigrant visa appointment, as the U.S. government does not directly notify selectees.

This alert has been provided by the BAL U.S. Practice Group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2023 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

U.S. Citizenship and Immigration Services announced Friday that it received 780,884 total registrations for this year’s H-1B lottery — a figure that shatters last year’s previous record of 483,927.

The agency attributed the dramatic rise in part to a large increase in the number of registrations submitted on behalf of beneficiaries with multiple registrations. USCIS distributed this chart, showing registration and selection numbers for fiscal years 2021-2024 (as of April 24, 2023).

Fiscal Year Total Registrations Eligible Registrations*            Eligible Registrations for Beneficiaries With No Other Eligible Registrations            Eligible Registrations for Beneficiaries With Multiple Eligible Registrations            Selections**
2021 274,237 269,424 241,299 28,125 124,415
2022 308,613 301,447 211,304 90,143 131,924
2023 483,927 474,421 309,241 165,180 127,600
2024 780,884 758,994 350,103 408,891 110,791

*The count of eligible registrations excludes duplicate registrations, those deleted by the prospective employer prior to the close of the registration period, and those with failed payments.

**USCIS said the number of selections was smaller in FY 2024 than in prior years primarily due to (a) establishing a higher anticipated petition filing rate by selected registrants based on prior years; and (b) higher projected Department of State approvals of H-1B1 visas, which count against the H-1B cap.

Beneficiaries With Multiple Registrations

The annual quota for cap-subject H-1B visas is 85,000, of which 20,000 are exclusively for U.S. advanced degree holders.

In its announcement, USCIS stated that the significant increase in the number of eligible registrations for beneficiaries with multiple eligible registrations raises “serious concerns that some may have tried to gain an unfair advantage by working together to submit multiple registrations on behalf of the same beneficiary.”

The agency said it has already “undertaken extensive fraud investigations” this year, would continue its investigations and may refer individuals or entities who submitted false attestations to “the appropriate federal law enforcement agencies for investigation and further action, as appropriate.”

USCIS also provided a reminder that the agency is working on a proposed rule to “modernize” H-1B requirements and oversight, including the registration process.

BAL Analysis: The 780,884 total registrations marked a 61.4% increase over the 483,927 from last year. The increase demonstrates the ongoing popularity of the H-1B program and the high demand for the limited annual number of visas. Employers are encouraged to work with their BAL attorney to consider alternatives for registrations that were not selected in March’s lottery.

The impact of USCIS’ investigation into potential fraud on this year’s selection or the possibility of a second lottery remains to be seen. BAL will continue to monitor the issue and will provide updates as information becomes available.

This alert has been provided by the BAL U.S. Practice Group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2023 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.